Anti Money Laundering Program

For the purpose of protecting the financial, legal and moral integrity of UniTeller that arises from the risk of laundering money and other illegal activities, our Legal and Compliance Department has the primary responsibility to monitor that all transactions that flow through the company meet the laws, rules and regulations established by governmental agencies such as: State Banking Departments, OFAC, FINCEN, and the IRS, among others.

AML Measures

Money laundering is the practice of inserting illegally obtained funds into the system in exchange for “clean” funds. Under U.S. law it includes the practice of engaging in financial transactions to conceal the identity, source, or destination of illegally gained money. These funds are illicitly introduced in the financial system, so that they may be transferred, invested or manipulated to appear as legal funds.

The Federal Government, under the Bank Secrecy Act, the Patriot Act, and the Money Laundering Control Act, has written strict laws and regulations to aid in preventing money laundering activities.

UniTeller operates under a strict program in order to meet the laws and regulations established by the government.

Abiding by these rules and regulations is part of our daily operating procedures.

Controls

UniTeller’s Compliance system filters each transaction based on lists of names involved in illegal activities, such as laundering of assets or drug trafficking, that are regularly published by OFAC and other government agencies. Other proprietary lists are also compiled, based on various factors:

Accumulated remittances, suspicious transactions, black lists, etc.

AML Manual for employees and agents.

Code of Conduct directed at UniTeller’s employees, with mandatory compliance initiatives, directed at strengthening the reliability of all of their activities.